(PS) Brown v. Preferred Employers Ins.
2:25-cv-00627
| E.D. Cal. | Jun 24, 2025Background
- Plaintiff Tahtiana Jade Brown filed a pro se complaint against Preferred Employers Insurance, Berkeley Technology, and Dan Moon, alleging bad faith in handling a workers’ compensation claim and related misconduct.
- The defendants were represented by counsel, but had not yet formally responded to the complaint at the time of the court’s review.
- Brown moved for leave to amend her complaint, expanding her claims and adding Lucidworks, Inc. as a defendant in proposed discrimination and retaliation claims.
- The court reviewed both the original and proposed amended complaint for federal subject-matter jurisdiction and duplicative litigation concerns.
- The federal claims alleged included retaliation and racial discrimination under Title VII and FEHA, but those claims were already pending in a previously filed action (Brown v. Lucidworks, et al.).
- The remaining claims were based on state law (e.g., insurance bad faith, negligence, privacy), with no valid federal question jurisdiction alleged or demonstrated.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Federal Question Jurisdiction over state law claims | Claims raise federal issues through HIPAA/privacy/due process | Not specifically argued; focused on lack of federal question | No federal question jurisdiction for state law insurance, privacy, or negligence claims |
| HIPAA/Privacy Violation Claims | HIPAA provides a basis for private action | Not specifically addressed | HIPAA does not provide a private right of action |
| Due Process Claims Against Private Parties | Procedural due process was violated | Not specifically addressed | No state action by private defendants, thus no federal claim |
| Duplicative Litigation | Claims under Title VII/FEHA legitimate in this new action | Not specifically argued | Duplicative of pending action, so federal discrimination claims dismissed |
Key Cases Cited
- Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375 (federal courts are courts of limited jurisdiction, with burden on party asserting jurisdiction)
- Caterpillar Inc. v. Williams, 482 U.S. 386 (federal jurisdiction requires federal question on face of the complaint)
- West v. Atkins, 487 U.S. 42 (to state claim under § 1983, must allege deprivation by person acting under color of state law)
- Lugar v. Edmondson Oil Co., 457 U.S. 922 (state action required for federal due process claims)
- Adams v. California Dep’t of Health Servs., 487 F.3d 684 (federal courts may dismiss duplicative later-filed suits)